Introducing the “In Favour Of” filter in Case Laws.
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Introducing the “In Favour Of” filter in Case Laws.
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of <h1>Enterprise Profits Taxable Only in Home State Unless Operating via Permanent Establishment in Another State, Deductions Allowed</h1> The profits of an enterprise from a contracting State are taxable only in that State unless the enterprise operates in the other contracting State through a permanent establishment. Profits attributable to such an establishment can also be taxed in the other State. Profits should be attributed as if the establishment were an independent entity, and deductions for expenses related to the establishment are allowed. Customary apportionment methods for determining profits are permissible if consistent with the article's principles. No profits are attributed for mere purchasing activities, and consistent methods should be used annually unless justified otherwise. Separate income items are governed by relevant articles.
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